First Name | Milan |
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Last Name | Steube |
Email Address | milans@cox.net |
Affiliation | |
Subject | Definition of Onshore Petroleum and Natural Gas Production Facility |
Comment | The terms "located at a well pad" and "associated with a well pad" or "associated with wells" used in the definition of an "onshore petroleum and natural gas production facility" and in other places in the regulation are not clearly defined in either 40 CFR Part 98 Subpart W or in ARB's MRR rule. A question seeking clarification of these terms from EPA resulted in the following response: "EPA has reviewed your question and is unable to respond at this time. Your question relates to an issue or issues currently the subject of ongoing litigation. Please monitor the website for any additional guidance that may be available in the future." As a result, operators of onshore oil and gas production facilities are each making their own interpretations of how to define their facilities to report 2011 emissions. There will likely be different interpretations by different operators, resulting in inconsistencies. If this new reporting requirement brings new facilities into the cap-and-trade universe or significantly increases reported emissions from facilities already in the universe, how will that affect the initial allocation process and those facilities' ability to comply with the requirements of the cap-and-trade rule? |
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Original File Name | |
Date and Time Comment Was Submitted | 2011-08-11 16:30:35 |
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